Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Capital gain - Valuation of the property sold by the assessee - reference to DVO - ITAT noted that the reference made by the AO to the VO was not in accordance with the relevant provisions of the Act. - The Tribunal analyzed the provisions of section 55A of the Act, both before and after the amendment effective from 01-07-2012. It determined that the amendment was not applicable to the relevant assessment year and, therefore, the reference made by the AO to the VO was not valid.
Capital gain - Valuation of the property sold by the assessee - reference to DVO - ITAT noted that the reference made by the AO to the VO was not in accordance with the relevant provisions of the Act. - The Tribunal analyzed the provisions of section 55A of the Act, both before and after the amendment effective from 01-07-2012. It determined that the amendment was not applicable to the relevant assessment year and, therefore, the reference made by the AO to the VO was not valid.
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